Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Object

Representation ID: 29818

Received: 17/03/2021

Respondent: Bridge View Developments Ltd

Agent: Bradley Stankler Planning

•Submission promotes the site located off North Cliffe Lane, Thornton (TH/022) as a housing allocation.
•Submission is on behalf of housebuilders committed to the early development of the site.
•Insufficient land has been identified in the plan for housing development. The plan fails to meet the spatial planning objectives.
•The site has been submitted previously at earlier stages of the plan’s preparation.

•Allocation of land for housing must be in accordance with the plan’s Strategic Policies on the housing requirement and spatial distribution.
•Policy SP1 states the Council will take a positive and proactive approach that reflects the NPPF’s presumption in favour of sustainable development. Of relevance is the key objective that the plan will ensure sufficient land is allocated to meet the District’s housing needs.
•Policy SP2 seeks to support, protect and enhance the roles of the Principal Towns and Local Growth Centres. Achieving a sustainable pattern of growth/development across the District.
•Policy SP3 uses a settlement hierarchy to achieve sustainable patterns of growth.
•Thornton is identified as a Local Growth Centre intended to fulfil a role in accommodating significant additional growth.
•Policy SP4 sets out that sites will be allocated using a sequential approach reusing previously developed land and buildings, greenfield opportunities within settlements, local green belt releases in sustainable locations.
•Policy SP5 lists the sites to be released from the Green Belt to meet housing and employment needs. Considers that exceptional circumstances exist to justify changes. Three sites in Thornton are identified for release.
•Policy SP8 sets out the housing requirement and distributes 2875 dwellings to Local Growth Centres (575 for Thornton). 15% of homes in these settlements should be on PDL.
•In Thornton greenfield land including Green Belt will need to be allocated for 489 dwellings.


•The 10% discount on committed sites for non-implementation is an under-estimate for sites in Thornton.
•Existing sites are long-standing commitments with constraints and are unlikely to make a meaningful contribution to the housing requirement for Thornton.
•The likely contribution from commitments will be 80%, therefore the committed sites are likely to achieve 35 dwellings, not 43. Land for a further 8 dwellings will need to be allocated.


•Application of the 10% reduction for non-delivery/non-implementation on the allocated sites is unreasonable and fails to take account of individual site circumstances.
•An assessment of the draft allocations indicates that a number of the sites are constrained and the blanket 10% reduction is not supported by evidence. The number of dwellings likely to be achieved will be significantly lower.
•(see separate representations on individual sites).
•These sites should be deleted as allocations: TH2/H, TH4/H, TH5/H, TH9/H, TH10/H, TH11/H. Also the following sites are constrained and would give a reduced capacity: TH1/HC, TH6/H. On this basis the allocations would not meet the housing target for Thornton leading to a shortfall of 198 dwellings. Compensatory land for housing will need to be allocated around Thornton to meet the spatial vision and objectives of the plan.
•In total there is a shortfall of 206 dwelling (198+8) which amounts to 36% of the 575 target for Thornton.
•Site TH/022 meets the policy requirements set out in the plan and should be allocated for housing.

Object

Representation ID: 29910

Received: 17/03/2021

Respondent: Bridge View Developments Ltd

Agent: Bradley Stankler Planning

Housing - Components of Supply

•The 10% discount on committed sites for non-implementation is an under-estimate for sites in Thornton.
•Existing sites are long-standing commitments with constraints and are unlikely to make a meaningful contribution to the housing requirement for Thornton.
•The likely contribution from commitments will be 80%, therefore the committed sites are likely to achieve 35 dwellings, not 43. Land for a further 8 dwellings will need to be allocated.
•Application of the 10% reduction for non-delivery/non-implementation on the allocated sites is unreasonable and fails to take account of individual site circumstances.
•An assessment of the draft allocations indicates that a number of the sites are constrained and the blanket 10% reduction is not supported by evidence. The number of dwellings likely to be achieved will be significantly lower.

Object

Representation ID: 29911

Received: 17/03/2021

Respondent: Bridge View Developments Ltd

Agent: Bradley Stankler Planning

•Site TH/022 was identified in a previous draft of the plan for housing with the only constraint on its suitability being Green Belt.
•The site represents an opportunity for allocation within a Local Growth Centre in accordance Polices SP1-3, SP5 & SP8.
•The site is located within Thornton, which is an identified Local Growth Centre;
•The site is well related to the existing built area with well-defined physical boundaries;
•Unlike other draft allocated sites, the site performs little Green Belt function;
•The site is demonstrably sustainably located and given the need to release additional Green Belt sites to meet the identified housing land requirement, its allocation for housing development in the Plan period, should be a priority;
•There are no technical infrastructure reasons preventing the site making an early contribution to meeting housing land requirements.
•Assessment confirms that the site fails to perform any of the purposes of including land within the Green Belt as set out in the NPPF and makes no contribution to the openness. Consideration should be given to the removal of the site from the Green Belt in accordance with Policy SP5:
•Check the unrestricted sprawl of urban areas: The site is contained by strong, defensible boundaries. Development of the site as proposed will not lead to the extension of the built-up area beyond existing development boundaries.
•Prevent neighbouring towns from merging: Allocation of the site as proposed will not lead to any neighbouring towns from merging.
•Assist in safeguarding the countryside from encroachment: The site is separated from the wider urban edge by a strong belt of mature trees. The site is therefore more closely related both visually and physically to the urban area.
•Preserve the special setting of historic towns: Allocation of the proposed site will have no significant impact on any heritage asset. Development of the site can take into account the need to protect the setting of the listed building adjoining the site to the north.
•Assist in urban regeneration: The Local Plan strategy encourages regeneration within the urban area, wherein the site is located.
•The new Green Belt boundary should follow the existing field boundaries and substantial tree belts. These are easily recognisable, defensible and clear boundaries on the ground and will lead to a more robust long-term defensible boundary between the urban area and wider Green Belt.
•The site is located in a highly sustainable location with access to public transport and a wide range of facilities within walking distance.
•Site is related visually and physically to adjoining development. It represents an opportunity to provide a greater choice of market housing.
•Site makes no material contribution to the character of the area.
•The site would make a significant contribution to meeting the shortfall in housing land.
•Site is not within an area liable to flooding.
•North Cliffe Lane would be able to accommodate the additional traffic generated. Highway safety will not be a constraint to the site’s development.
•No trees within the main body of the site. Those important boundary trees worth of retention can be accommodated as part of the site’s development, forming the new Green Belt boundary.
•A buffer will be required to retain the setting of the listed buildings at Hoyle Ing House.
•Gas, electricity and drainage are available adjacent to the site. SUDS techniques will be explored.
•Site is available, suitable and deliverable.
•The site satisfies the release criteria for housing sites.
•The draft plan is currently unsound and it is requested that Site TH/022 be a preferred allocation for development.

Comment

Representation ID: 29918

Received: 17/03/2021

Respondent: Bridge View Developments Ltd

Agent: Bradley Stankler Planning

TH1/HC
Comment on Green Belt Function: N/A

General Comment: Long-standing committed site with outline planning permission, expiring July 2021. Sloping site requiring access improvements.

Draft Local Plan Estimated Gross Capacity: 11

Evidence Based Conclusion On Suitability & Capacity: 11 dwelling capacity as per planning permission, but doubts as to deliverability as the junction of Hill Top Road and Wiken Lane is substandard, requiring improvement.

Object

Representation ID: 29919

Received: 17/03/2021

Respondent: Bridge View Developments Ltd

Agent: Bradley Stankler Planning

TH2/H

Comment on Green Belt Function: N/A

General Comment: Prominent hillside site, northern part of which is site steeply. Development of all of site would lead to adverse impact on character of village. Only southern part of site should be developed.

Draft Local Plan Estimated Gross Capacity: 150

Evidence Based Conclusion On Suitability & Capacity: 75 dwelling capacity due to landscape impact of development of northern part of site.

Comment

Representation ID: 29920

Received: 17/03/2021

Respondent: Bridge View Developments Ltd

Agent: Bradley Stankler Planning

TH3/H

Comment on Green Belt Function: Limited Green Belt function. Well defined physical boundaries.
General Comment: Well related to built up area with good road frontage, adjoining a number of listed buildings.
Draft Local Plan Estimated Gross Capacity: 15
Evidence Based Conclusion On Suitability & Capacity: 15 dwelling capacity

Object

Representation ID: 29921

Received: 17/03/2021

Respondent: Bridge View Developments Ltd

Agent: Bradley Stankler Planning

TH4/H

Comment on Green Belt Function: N/A
General Comment: Site well related to village with good road frontage but development will be highly visible from south. Rear part of site slopes steeply. Site adjoins listed building.
Draft Local Plan Estimated Gross Capacity: 10
Evidence Based Conclusion On Suitability & Capacity: 6 dwelling capacity to site frontage to ensure no adverse landscape impact and no harm to setting of adjacent listed building.

Object

Representation ID: 29922

Received: 17/03/2021

Respondent: Bridge View Developments Ltd

Agent: Bradley Stankler Planning

TH5/H

Comment on Green Belt Function: N/A
General Comment: Partially wooded site within built up area adjoining listed building. Bronte Way public footpath crosses site. Access from Hill Top Road constrained. Rear part of site slopes steeply.
Draft Local Plan Estimated Gross Capacity: 12
Evidence Based Conclusion On Suitability & Capacity: NIL dwelling capacity due to combination of significant access constraint, PROW crossing site and extensive tree coverage.

Comment

Representation ID: 29923

Received: 17/03/2021

Respondent: Bridge View Developments Ltd

Agent: Bradley Stankler Planning

TH6/H

Comment on Green Belt Function: N/A
General Comment: Brownfield site within defined village limits with good road frontage in conservation area. Site contains former mill pond. Southern part of site well treed. Partially greened over.
Draft Local Plan Estimated Gross Capacity: 50
Evidence Based Conclusion On Suitability & Capacity: 50 dwelling capacity but deliverability uncertain due to potential mill pond contamination and ecological interest and need to retain trees.

Comment

Representation ID: 29924

Received: 17/03/2021

Respondent: Bridge View Developments Ltd

Agent: Bradley Stankler Planning

TH7/H

Comment on Green Belt Function: N/A
General Comment: Small site within built up limits with limited capacity
Draft Local Plan Estimated Gross Capacity: 50
Evidence Based Conclusion On Suitability & Capacity: 50 dwelling capacity but deliverability uncertain due to potential mill pond contamination and ecological interest and need to retain trees.